Contact centers originating calls to wireless numbers must comply with the Telephone Consumer Protection Act (“TCPA”, see e.g., 47 U.S.C. §227) that regulates, in part, aspects of originating calls to wireless numbers using certain types of equipment. Specifically, the TCPA requires that a call to a wireless number should be manually dialed if there is no express consent provided by the called party to receive calls at that number, as opposed to using an autodialer. If express consent has been provided, then the contact center may use an autodialer to dial that wireless number.
In various circumstances, a contact center attempting to reach an individual may discover the individual has relinquished their telephone number. In such cases, the telephone number is “obsolete” with respect to the targeted individual. The reasons for this can vary. For example, the telephone number may have been a wireline number and the individual may have moved to another city or state. The user may not have been able to, or may have chosen not to, port their number to their new location. In other examples, the telephone number may have been a wireless number and the individual may have chosen to discontinue their mobile phone service. In certain instances, the individual may have been delinquent in paying their bills and the service may have been disconnected with the number removed from service. The individual may restore service, but with another number. These and other situations may result in a telephone number being relinquished or becoming obsolete. If the number is dialed shortly after being relinquished, an intercept announcement may be provided to the caller. After a while, the service provider may reassign the number to another individual. Consequently, calls to that number which are intended for the previous subscriber may be answered by the current subscriber.
The contact center may dial the telephone number and discover that the number is no longer in service or has been reassigned. In either case, the number is considered obsolete and is no longer associated with the individual that the contact center is attempting to reach. In such circumstances, the contact center may utilize a third-party vendor to locate a current telephone number for that individual. Such vendors are sometimes referred to in the industry as “skip-trace” vendors. These may provide a real-time service where queries are processed to return a skip-trace number. The origin of this term may be related to usage in a debt-collection context, where an individual owes money for a debt, and has attempted to “skip-out” from paying their debt by purposefully relinquishing their telephone number and obtaining a new one. By obtaining a new number, the debtor may avoid being contacted using the old number. The skip-trace vendor will “trace” the individual by searching for a new number for that individual and provide it to the debt collector for a fee. The debt-collector, in turn, may operate or hire the contact center to contact the debtor.
In practice, there is little difference between a skip-trace number provided by a skip-trace vendor to a debt collector and a telephone number provided by a directory service provider to a contact center. However, reference to a skip-trace number is based on the context of a debt-collector attempting to contact an individual that owes a debt, and implies that the debt-collector has an obsolete telephone number. Thus, the skip-trace number is the purportedly current number of the debtor. Since the skip-trace vendor may receive compensation for providing the skip-trace number, the skip-trace vendor may not always fully verify that the number is correct before providing it.
When the contact center dials the skip-trace number, the contact center must still comply with the terms of the TCPA. As noted above, the skip-trace number may not always be correct. Thus, one problem addressed by the present disclosure is ensuring that compliance related regulations and policies are adhered to by the contact center while also complying with the TCPA mandate that prohibits using an “autodialer” to call wireless numbers without express consent. It is against this backdrop that the concepts and technologies disclosed herein are presented.